Dividend Withholding Tax (DWT)

Who should withhold DWT?

DWT is deducted from all relevant distributions. Relevant distributions include all payments normally treated as a distribution for Income Tax and Corporation Tax (CT) which are:

  • normal cash, and non-cash, dividends
  • expenses incurred by close companies in providing benefits or facilities for a participator in the company
  • excess interest paid by close companies to directors
  • scrip dividends of quoted companies. These are additional share capital of a quoted company taken instead of a cash distribution
  • and
  • scrip dividends of unquoted companies.

DWT is also deducted where exemptions and exclusions have been disapplied for distributions made to an associated entity:

  • in zero or no-tax jurisdictions
  • or
  • in jurisdictions on the European Union (EU) list of non-cooperative jurisdictions.

These are known as outbound payment defensive measures.

When DWT should not be deducted

Subject to the outbound payments defensive measures, DWT should not be deducted from:

  • dividends paid to Government ministers, in their capacity as ministers
  • dividends paid to the National Pensions Reserve Fund Commission
  • distributions made by an Irish resident subsidiary company to its EU parent company, where withholding tax is not allowed under EU legislation
  • dividends paid to a shareholder who makes an election under a stapled stock arrangement to receive their dividend from an associated non-resident company
  • distributions made out of exempted profits from the occupation of woodlands
  • distributions made out of certain exempted income from mining operations
  • and, or
  • distributions made by an Irish resident company to another Irish resident company of which it is a 51% subsidiary.

Companies should not deduct DWT from a distribution if they hold a valid DWT exemption declaration form for those subject to outbound payments defensive measures.  These are either a:

For further information, please see Tax and Duty Manual Part 33-05-01.

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